CG12944 - Capital sums from assets: capital sum for forfeiture of rights


There is a deemed disposal where a capital sum is received as compensation in return for

  • forfeiting or surrendering rights
or
  • refraining from exercising rights.

Examples include

  • the release of another person from a contract, such as
  • a contract of service, O'Brien v Benson's Hosiery (Holdings) Ltd (53TC241), see CG12987+ and CG13068a
or
  • a restrictive covenant, see CG68060.

The 'rights' must be an asset for Capital Gains Tax purposes, see CG12000+.